Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

Blog Symposium: The impact of the revised World Anti-Doping Code on the work of National Anti-Doping Agencies. By Herman Ram

Introduction: The new WADA Code 2015
Day 2: The “Athlete Patient” and the 2015 World Anti-Doping Code: Competing Under Medical Treatment
Day 3: Proof of intent (or lack thereof) under the 2015 World Anti-Doping Code
Day 4: Ensuring proportionate sanctions under the 2015 World Anti-Doping Code

Editor's note
Herman Ram is the Chief Executive Officer of the Anti-Doping Authority the Netherlands, which is the National Anti-Doping Organization of the country. He has held this position since 2006. After working twelve years as a librarian, Herman Ram started his career in sport management in 1992, when he became Secretary general of the Royal Netherlands Chess Federation. In 1994, he moved on to the same position at the Netherlands Badminton Federation. He was founder and first secretary of the Foundation for the Promotion of Elite Badminton that was instrumental in the advancement of Dutch badminton. In 2000 he was appointed Secretary general of the Netherlands Ski Federation, where he focused, among other things, on the organization of large snowsports events in the Netherlands. Since his appointment as CEO of the Anti-Doping Authority, he has developed a special interest in legal, ethical and managerial aspects of anti-doping policies, on which he has delivered numerous presentations and lectures. On top of that, he acts as Spokesperson for the Doping Authority. Herman Ram holds two Master’s degrees, in Law and in Sport Management.

Introduction
The 2015 World Anti-Doping Code is not a new Code, but a revision of the 2009 Code. In total, 2,269 changes have been made (see here for the redlined version). Quite a number of these changes are minor corrections, additions and reformulations with little or no impact on the work of NADOs. But the number of truly influential changes is still impressive, which makes it hard to choose.

Luckily, WADA has identified the – in their view – more significant changes in a separate document and I have used this document to bring some order in a number of comments that I want to make on the impact of those revisions on our daily work.

Part of what follows is based on our experiences with the implementation of the revised Code so far, but quite a bit of what follows cannot be based on any actual experience, because the revised Code has only been in place for seven months, and only a rather small number of disciplinary procedures in relatively simple cases have come to a final decision under the revised rules. As a result, and because I am not in the business of predicting the future, on this occasion I have decided to share some of my expectations with you. Only the future can tell whether I am right on those issues.

Theme 1: sanctions
Probably the most discussed aspect of the revision is the longer period of ineligibility that can be imposed on – as WADA formulates it – ‘real cheats’. In other cases, especially cases of unintentional violations, the revision should lead to more flexibility to impose lower sanctions. Due to the amendments in most cases it will be crucial to establish ‘intent’ – or the lack of it – in order to be able to determine the appropriate sanction. And because of the Strict liability principle that applies to the burden of proof in cases with Adverse Analytical Findings, NADOs have not focused very much on the establishment of ‘intent’, simply because under the previous Codes it was not relevant for the outcome of most cases.

In the case of non-specified substances, it is now up to the athlete to prove that the violation was not intentional, and in the case of specified substances it is up to the (N)ADO to prove intent. This is new, and our current practice shows that this kind of evidence is very hard to deliver for both parties. As a consequence, four year sanctions have been imposed rather matter-of-factly until now in cases where non-specified substances are involved. And such severe sanctions will remain common if non-specified substances are detected, but they will be quite rare in other cases. No doubt, jurisprudence will be developed that will help to assess specific situations, but for most cases the four year sanction will more or less automatically result from the simple fact that a non-specified substance is involved.

Some exploratory analysis of the sanctions imposed under the 2009 Code for specified substances has shown that panels have already established a practice with a lot of flexibility in those kind of cases under the 2003 and 2009 Codes, and I do not expect major changes there.

Quite interesting from our (NADO’s) point of view is Article 10.6.3, which introduces a role for both the (N)ADO with result management responsibility and WADA in cases where athletes or other persons promptly admit an anti-doping rule violation. If both the (N)ADO and WADA agree, a sanction reduction from four years to a minimum of two years is possible. We do not yet know what WADA’s position will be in this kind of cases, but I do know that many NADOs will be inclined to grant a reduction of the period of ineligibility, because we want to stimulate admissions as much as possible. Information given by athletes and other persons is most valuable, and (less important, but still…) we can spare ourselves a lot of costly work in the process.

Somewhat related to prompt admissions (not new, but amended and expanded in the revised Code) is the possibility to reduce sanctions based on substantial assistance (Article 10.6.1). Because of the growing importance of Investigations and Intelligence (see Theme 3 below) and the increased emphasis on Athlete Support Personnel (Theme 4) I think that we will see that this Article will become more important in the work of NADOs. It seems to me that the revisions will help us considerably in all cases where athletes or other persons need reassurance that an agreed-upon reduction of sanctions will be respected ‘no matter what’. At the same time, more information will become available that may help us in uncovering and prosecuting other anti-doping rule violations.

Theme 2: proportionality and human rights
I can be quite short here: I have not identified a single consequence of this Theme for the NADO that I work for, and I can hardly imagine that other developed NADOs will see this differently. This is not because this Theme is not important (quite the contrary) but because NADOs do not need extra encouragement in order to ensure that proportionality and human rights are taken into consideration on an everyday basis. And because – at least in Europe – data protection issues and the related issues of public disclosure and the protection of minors are primarily governed by legislation, not by the Code.

Theme 3: Investigations and intelligence
Indeed, the development of ‘Intelligence & Investigations’ is one of the major issues that quite a few NADOs are dealing with now. In less than two years’ time, more than a dozen NADOs have attracted new staff for this purpose, and cooperation between NADOs (and some IFs) in this field is gradually developing, at a pace that is primarily determined by taking care of the legal side of things. The Code revision has not initiated this development, but it certainly confirms and strengthens it. And we are well aware that Intelligence has played a major role in practically all cases (old and recent) where large-scale, organized, doping practices have been uncovered. Which does not mean that we are all prepared for this kind of thing…

First of all, it is necessary to develop and sign bilateral cooperation agreements in which the preconditions for sharing information between (N)ADOs are defined. I have signed several, and there are more to come. But it is also necessary to start and develop a cooperation with customs and law enforcement agencies, and this kind of cooperation needs even more legal preparation in order to be successful (or just possible). Indeed, information sharing with government agencies is just as logical as it is complicated in practice.

I do not know one NADO that does not feel the need for cooperation with law enforcement agencies. And that fact, supported by the revised Code, means that NADOs are slowly but surely getting better acquainted with government agencies. It is my opinion that several legislation proposals in various countries in Europe illustrate this development nicely. Countries which have done without specific anti-doping legislations for years – including my own country – are now working on legal measures that aim to facilitate a close(r) cooperation between governments and (N)ADOs (in line with the expansion of Article 22.2 in the 2015 Code).

The investigative powers of Intelligence Officers of NADOs on the one hand, and law enforcement agents on the other hand, are wide apart. In most countries, an Intelligence Officer has no other rights than any citizen, while there are elaborate laws that define and regulate what law enforcement officers may and may not do. The gap between the two has to be narrowed, in order to facilitate and stimulate further cooperation. Which means that Intelligence Officers will need to have specific authorizations that enable them to do their job within sport, but without becoming law enforcement officers themselves. The solutions will be different per country, but the common factor will be that NADOs will have more tools to fulfil their tasks.

Apart from these legislative and regulatory developments, which open doors that have been firmly closed until now in many countries, there are not many ’quick wins’ to be expected because of ‘Intelligence & Investigations’. In the long run, however, ‘Intelligence & Investigations’ will probably have a significant impact on the effectiveness of doping control programs, which will not really become ‘smarter’ (more brain power has been invested in the testing programs under the 2003 and 2009 Codes than most people can imagine), but certainly more ‘targeted’ and tailor-made. This may be an equally important effect of ‘Intelligence & Investigations’ as collecting evidence.

The extension of the statute of limitations (Article 17) to ten years will not make a big difference in numbers, but the cases where this extension pays off, will for a large part be the kind of cases that we find especially important to bring to justice. There is a downside to this as well, of course, and one of the aspects that I have not seen mentioned often is the fact that relevant samples will have to be stored for another two years, which will lead to additional costs. Few people realize how expensive the storing of samples – under the right conditions – is.

Theme 4: Athlete Support Personnel (ASP)
This Theme is closely connected to Theme 3, because anti-doping rule violations by Athlete Support Personnel cannot be proven by the traditional means of proof of ADOs, i.e. the analysis of urine and blood samples. There can be no doubt that catching those coaches and doctors that supply and administer doping to the athletes must be a high priority for NADOs. We are well aware that athletes do not function in a vacuum. As a consequence, NADOs will dedicate a considerable part of their ‘Intelligence & Investigations’ capacity to ASP. A rise in the number of cases where ASP is involved can be predicted, although – unfortunately – a huge effect is unlikely. Not only because these cases will always be hard to prove (no matter what) but also because large groups of ASP are not (properly) bound by anti-doping regulations. The seriousness of this problem varies per country and per sport (discipline), and the problem may – at least partly – be solved through legislation. But in my own country, I do not see how the Code revision will help the NADO in prosecuting ASP, unless and until we manage to find ways to sufficiently bind all relevant ASP to our rules.

The new anti-doping rule violation ‘Prohibited Association’ brings us some serious new challenges, I think. One of them being the burden of proof, which often will not be easy to discharge. Here again, ‘Intelligence & Investigations’ will play a crucial role. But even if it can be proven that an athlete is working with an ineligible coach, trainer or doctor, there may be several legal challenges if the ineligible person has a private practice outside organized sport, and working with athletes is the livelihood of that person.

Theme 5: Smart testing and analyzing
As I mentioned above (see Theme 3) ‘Intelligence & Investigations’ will probably have a significant positive impact on the effectiveness of doping control programs. However, it remains to be seen whether this effectiveness will show in terms of the detection of more anti-doping rule violations, or in a better deterrence. Whichever it will be, a consequence of the development towards more targeted and tailor-made testing and analyzing, is that the price of testing will go up. Tailor-made testing means more individual testing, on odd hours, in (sometimes) strange places. This is – no surprise – considerably more expensive than testing a number of players at random after a training session of a team.

On top of that, the Technical Document for Sport Specific Analysis (TDSSA, https://wada-main-prod.s3.amazonaws.com/resources/files/wada-tdssa-v2.2-en.pdf) that has been developed after the implementation of the revised Code (based on Article 6.4 of that Code), prescribes a minimum percentage of additional analyses per sport discipline, with even more cost increase as a consequence. Some NADOs have managed to get additional funding in relation to these new requirements, but most of us have not (and not many of us foresee a budget increase in the near future). So the global number of tests performed by NADOs will in all likelihood decrease.

Whether this decrease in numbers will be acceptable, depends on the value added by the additional analyses that are now performed. If less tests bring more proof, then it is a good development. However, for the time being, there is no way to tell. And it is predictable that decreasing numbers of tests (the number of tests performed being the most commonly used measuring stick to assess the performance of a NADO) will generate critical questions about how serious we take the fight against doping in sport.

While I am writing this contribution, we are in the middle of the ‘IAAF controversy’, following the leakage of confidential information to the media, and the subsequent publication of sensitive data. I am not in the position to comment on what exactly is right and wrong in this case (I simply do not know) but I do know that the IAAF anti-doping program is ‘smarter’ than most, and that it can show results that few IFs can. Nonetheless, the public discussion is focusing on what has not been accomplished with all these data. So the large amounts of data that become available through ‘smart’ testing and elaborate biological passport programs, may become a burden instead of a blessing if the burden of proof is not reached in too many cases. Which – I fear – may be the case.

Theme 6: International Federations and NADOs
Another development that is not initiated by the Code revision – but certainly is supported and accelerated by it – is the improvement of NADO-IF cooperation. The revised Code clarifies and solves several of the problems that we have experienced with the 2009 Code. Examples are the control of therapeutic use exemptions (Article 4.4), the testing authority during international events (Articles 5.3, 5.2.6 and 7.1.1), and the coordination of whereabouts failures (Article 7.1.2). All these changes are improvements.

However, cooperation is more in the soul than it is in the rules, and we must acknowledge and accept that there are relevant differences between NADOs on the one hand and IFs on the other hand, in terms of culture, position and tradition. WADA has created Ad Hoc Working Groups of NADOs and IFs separately, and these groups have made inventories of existing problems that are subsequently brought to the table in joint meetings. The Articles in the Revised Code that underline the need for better cooperation will have no meaning if we stay separated in two worlds. But the impact will be huge, if and when we benefit from each other’s knowledge and experience. And although I am not an optimist by nature, I am pretty sure that this will work out fine.

Theme 7: A clearer and shorter Code
I think it is obvious that this Theme is quite ambitious, and I can only regretfully conclude that the revised Code is neither clearer, nor shorter than the 2009 version. The Code is the most important legal tool in the anti-doping world, and both lawyers and administrators may (and do) delight in the fact that the Code has proven to be an indispensable tool in our toolkit. It is, however, not a tool for athletes (except for those who are also lawyer or administrator) and it will never be. Clarity about the rules is delivered by the Education departments of NADOs, in the form of numerous publications, leaflets, manuals and (more and more) digital tools. And it is my personal opinion that there is not much wrong with accepting that the Code is not meant to educate athletes, but to protect them.

Miscellaneous
It is difficult to choose what other aspects of the revised Code are worth mentioning here. Let me name only a few.
The new possibility for an athlete to return to training during the last part of the period of ineligibility imposed on him (Art. 10.12.2), is – in my opinion – a balanced compromise between the need to fully execute sanctions, and the interests of team members that have not been sanctioned themselves. However, this refinement of the sanction regime further complicates the task that has been a burden for many NADOs for years already: how to monitor that sanctions are observed correctly and fully. This monitoring task usually cannot be fulfilled without the help of sport federations and clubs, and – to a certain extent – fellow athletes. Publicly known elite athletes will hardly have an opportunity to violate their sanction without being ‘caught’, but for lesser gods the situation is different, which fact collides with the Level playing field that we want to achieve.

Article 6.5 of the revised Code addresses the storing of samples for further analysis. It is good that these rules are now clarified, because it is to be expected that the percentage of samples that are stored for future analysis will rise over the years. The revised rules are meant to do justice to both the athlete and the (N)ADO and I think they actually do that, although I am sure that both NADOs and athletes will disagree in any particular case they are involved in.

The importance of the explicit wording of the Articles 20.4.3 and 22.6 that address the need for NADOs to be free from interference in our operational decisions, cannot be overestimated. Anti-doping issues can get a lot of attention in the media, and that may or may not lead to unleashing certain political powers. In my country, parliamentary questions have been asked about specific doping cases on several occasions. Thankfully, in no case this has led to actual interference in our work, but it is very good that the Revised Code is there to ward off such interference in countries where this may be necessary.

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Asser International Sports Law Blog | FIFA’s provision on the protection of minors - Part 2: The 2009 reform and its aftermath. By Kester Mekenkamp.

Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

FIFA’s provision on the protection of minors - Part 2: The 2009 reform and its aftermath. By Kester Mekenkamp.

Editor’s note: Kester Mekenkamp is an LL.M. student in European Law at Leiden University and an intern at the ASSER International Sports Law Centre. This blog is, to a great extent, an excerpt of his forthcoming thesis, which he shall submit in order to complete his master’s degree.


This is the second part of a three-piece blog on FIFA’s provision on the protection of minors, Article 19 of the Regulations on the Status and Transfer of Players. The contribution in its entirety aims to provide an encompassing overview of the rule’s lifespan since its inception in 2001. The previous (first) part has shed light on the “birth” and “first years” of the provision, and as such illustrated the relevant developments from 2001 till 2009. This second part covers the rule’s “adolescent years”, which span from 2009 to the present. The major changes put forward in the 2009, 2015 and 2016 versions of the RSTP will be addressed. Thereafter the important CAS decisions concerning Article 19, Muhic, Vada I and II, FC Barcelona, RFEF, and the FIFA decisions relating to Real Madrid and Atlético Madrid, will be scrutinized. The third, and final, part will constitute a substantive assessment of the provision under EU Internal Market law.

Given that the version adopted in 2008 left Article 19 untouched, the 2009 RSTP represented the next significant step in the regulation of the protection of minors. It had become clear that the system as used up to that point was inadequate to achieve its goal,[1] most notably because several national associations still neglected to strictly apply the rules.[2] In response to this perceived failure, a new set of rules and procedures was adopted and came into force on 1 October 2009: the creation of a special FIFA oversight sub-committee of the PSC, the introduction of a special provision on football academies, and the instalment of a transfer matching system.[3] Importantly, with the enactment of these new regulations, Articles 19 and 19bis RSTP were included in the set of provisions binding upon the national level, which consequently had to be incorporated into the national associations’ regulations without alteration.[4]

This new 11-member PSC sub-committee (consisting of representatives of the confederations, leagues, clubs, players and the PSC’s chairman and deputy chairman) became the supervising body concerning the examination, and potential approval, of every international transfer and first registration of a minor player.[5] Its approval is mandatory and needs to be obtained prior to any request for any association’s ITC-request.[6] Moreover, non-compliance can be sanctioned by the FIFA’s Disciplinary Committee, although a limited exception from this obligation exists for minor amateur players.[7]

Article 19bis RSTP on the registration and reporting of minors at academies was another substantial modification with respect to the protection of minors.[8] A football academy is defined by the regulations as “an organisation or an independent legal entity whose primary, long-term objective is to provide players with long-term training through the provision of the necessary training facilities and infrastructure. This shall primarily include, but not be limited to, football training centres, football camps, football schools, etc.”[9] With the creation of this new provision, all minor players that attend an academy, indifferent to whether or not that academy takes part in a national championship or has a legal, financial or de facto link to a club participating in a national championship, must be reported to the national association upon whose territory the academy operates.[10] This regulation of academies resembles an attempt to deal with what was previously a major loophole, the unregistered academies.[11]

The third major change was the instalment of a transfer matching system (“TMS”), which is a web-based data information system that, first of all, aims to simplify the processing of international transfers.[12] Its task is to provide more details to football’s governing bodies on all transfers taking place.[13] This should furthermore increase the transparency of the individual transactions, and in doing so, it will “improve the credibility and standing of the entire transfer system, and additionally also “safeguard the protection of minors”.[14] In practice, the TMS is a central database that monitors the international movement of players. As mentioned earlier, every application for an international transfer by a minor player must receive the approval of the PSC sub-committee. This process is managed through the transfer matching system, the details of which are stipulated in annexe 2 of the RSTP.[15] The sub-committee decides with three of its members, or, in urgent cases, through a sole member acting as “single judge”.[16] The national association wanting to register a player, files the application for an approval of an international transfer (or first registration) into the TMS.[17] Accompanying this application, the TMS requires a great number of specific documents, depending on the facts of the case and the exception that is being invoked.[18] This mandatory release of information spans documentation on, inter alia: academic and football education, accommodation, player’s and/or player’s parent(s) contract, parental authorisation and a birth certificate.[19] Subsequently, the sub-committee decides whether or not it gives its approval. If so, an ITC will be delivered via the TMS and the transfer can be finalized.[20] Parties involved have 10 days to inquire for the grounds of the decision, after that an appeal before the CAS is still open. Note that this procedure for minors differs from a regular international transfer, in that for the latter there is no substantive review by a third party. The clubs provide the relevant information and the TMS merely, automatically, checks whether the two strands of facts match.[21]


The Elmir Muhic case

The regulatory system laid down in the 2009 RSTP operates in roughly the same manner today, as the revisions of 2010, 2012, 2014, 2015, did not substantially amend the core rules.[22] The case law of the CAS during this period, from 2009 to 2012, provides some examples of the application and interpretation of the 2009 rules.

In Elmir Muhic v. FIFA, a 16-year-old football player from Bosnia-Herzegovina joined the German OFC Kickers Offenbach.[23] Following the PSC sub-committee refusal to give its approval, the case ended up before the CAS. The Panel found that none of the three exceptions applied in the matter at hand. It did specify, in relation to the “parents-rule” of Article 19(2)(a), that the term “parents” needs to be applied stricto sensu.[24] Even though it could “conceivably cover situations beyond the natural parents”, such was not the case here.[25] Muhic’s parents still lived in Bosnia and Herzegovina (and it remained uncertain why they did not joined their child), while the player stayed at his aunt’s house.[26] The Panel stated that an aunt (and relatives alike) cannot replace the player’s parents in order to invoke the exception.[27] 


The Vada II case

Around the same time, Vada II made an important contribution to the application of Article 19(2)(b) (the first case had evolved along the lines of the Acuña award).[28] Valentin Vada was a football player living in Argentina, with dual citizenship. Next to possessing the Argentinian nationality, Vada also owned an Italian passport.[29] The 16-year-old was of the opinion that he could transfer to the French Club Girondins de Bordeaux, based on the “EU and EEA-rule” of Article 19(2)(b) RSTP.[30] FIFA’s single judge rejected the request, as he found the facts of the transfer not to match the strict requirements of the exception.[31] The arbiter reasoned that this exception is based on the criterion of territoriality, not nationality, and thus only refers to “a transfer taking place within the territory of the EU or EEA”.[32] Therefore, as Vada wished to transfer from an Argentinian club, Article 19(2)(b) RSTP could not be applied. Be that as it may, the CAS Panel argued (in length) otherwise. It agreed that the “EU and EEA-rule” merely stipulates a criterion of territoriality not nationality.[33] Still, it also noted that the FIFA’s RSTP commentary (as abovementioned) revealed that this exception was included in the 2001 informal agreement between FIFA/UEFA and the Commission in order for it to respect EU free movement law.[34] Thus, this objective to comply with EU free movement rights could not be ignored.[35] Additionally the CAS found, in line with FC Midtjylland, that the list of exceptions in Article 19(2) is not exhaustive.[36] This was supported by a document submitted by Girondins de Bordeaux setting out the case law of the PSC sub-committee. It explained that “if a club believes that very special circumstances, which do not meet any of the exceptions provided…the association of the club concerned may, on behalf of its affiliate, submit a formal request in writing to the FIFA sub-commission to consider the specific case and make a formal decision”.[37] Moreover, the document showed that the sub-committee in the majority of cases takes free movement law into consideration when “assessing the transfer of a player who, with a passport from an EU or EEA country, wishes to register with a club in an EU or EEA country”.[38] Consequently, the Panel accepted an unwritten exception allowing a player such as Vada, with the nationality of one of the EU or EEA member countries, to invoke Article 19(2)(b) RSTP.[39] 


The Spanish lawbreakers

From 2013 onwards the three biggest and richest football clubs in Spain, at the same time belonging to the top 15 clubs worldwide, Atlético Madrid, Real Madrid and FC Barcelona, found themselves embroiled in a number of legal disputes as a result of signing minors.[40] A significant step unto its own, as it demonstrates that FIFA will not shy away from taking on the big iconic clubs when enforcing its regulations.

This “Spanish saga” kicked-off with a dispute concerning a US teenager, of 13 years old, who moved to Spain together with his parents and wanted to register with Atlético Madrid in September 2012.[41] Once more, the main question was whether the factual constellation of the case supported the application of the “parents-rule” (did the parents move to the country of the new club for reasons not linked to football?), and again the Panel stressed, in line with both Acuña and FC Midtjylland,[42] the need to apply the protection of minors rules in a “strict, rigorous and consistent manner”.[43] This means, following its decision in Vada I, that the family’s move must be unconnected altogether to football.[44] It is insufficient to establish that the move is partially connected to their child’s football activities, although not being the primary aim.[45] The Panel’s factual assessment distinguished multiple relevant elements to come to a decision on the possible application of the exception. Contra: the short timeline (six weeks) between the minor’s arrival in Madrid and the registration request (which hints at a previous intention); the player’s previous footballing activities; the player’s statement, reported on his school’s official website, “that the reason of his move to Spain was the possibility that he has been given to play with the Club Atlético de Madrid”.[46] Pro: the family of the player is partially Colombian, which connected them to Spain for reasons of culture and language; “The family is wealthy and…the basic maintenance of the family is not dependent of a working activity of the parents”; The player’s sister had already moved to Europe for her studies; The first preparations were undoubtedly made several months before the interaction with the club commenced; The club does not have a particular interest in the player “other than having in its team a teenager which may have a certain talent for football, such as many others in the Madrid area”.[47] In sum, the CAS concluded that, due to the exceptional facts, there is no link between the move of the family and their son’s football activities.[48]


The FC Barcelona case

Atlético’s fellow-townsman Real Madrid ended up in a likewise dispute with FIFA regarding a 13-year-old player from Venezuela.[49] The main hitter however was the case regarding their Catalonian archenemy: FC Barcelona.[50] The FIFA TMS, in January 2013, became aware of a potential breach, which ultimately lead to a case involving registrations of 31 minors.[51] These players, of various nationalities, were registered at FC Barcelona in the period from 2005 until 2012.[52] Via the FIFA Disciplinary Committee and Appeal Committee, who both found the club to have violated i.a. Articles 19(1), 19(3), 19(4), 19bis, and Annexe 2 of the RSTP, the case ended up before the CAS.[53] The Panel addressed the different potentially breached articles in a consecutive order, starting with Article 19(1) RSTP. The Panel found FC Barcelona to have infringed this provision with respect to nine players. The club had tried to shelter behind the fact that it had complied with all the rules laid down by the regional Catalonian football association, and, as such, had acted rightfully. The Panel held instead that the ban on internationally transferring minors is without doubt “addressed to both ‘associations’ and clubs”.[54] It thereby emphasized that national associations are paramount to the enforcement of FIFA’s statutes, and in the extent thereof the enforcement of the RSTP. Regional associations, such as the Catalonian, cannot govern the international transfer of players.[55] Given that clubs are the starting point of every international transfer, they “must primarily observe this ban”. The Panel stressed furthermore that Article 19(4) RSTP marks this by obliging the associations to ensure the clubs’ compliance in this matter, and moreover, Article 1(4) RSTP, explains that the Regulations “are binding for all associations and clubs”.[56] FC Barcelona may thus not hide behind apparent mistakes/breaches by both the Catalonian and the Spanish football associations, given that it “did not even try to request the transfers based on any one of the exceptions”.[57] Furthermore, FC Barcelona “should have been aware of the simple fact that they [the Spanish and the Catalonian associations] could not register the minors in any legitimate way under the RSTP”, which the CAS compared to “wilful ignorance” or, the “deliberate shutting of eyes”.[58]

Of the group of minors at the centre of the dispute, three were below the age of 12. FC Barcelona put forward a restrictive reading of the personal scope of application of the Articles 19 and 9(4) RSTP (2010 edition), arguing “that there are no prohibitions for the transfer of players under the age of 12”.[59] It thereby relied on Article 9 of the 2006 RSTP Commentary that stipulates “for players younger than 12, the Regulations do not provide for an obligation to issue an ITC for international transfers”.[60] The Panel nonetheless made short work of this argumentation by explaining that Article 9(4) RSTP’s absence of an obligation to issue an ITC for under-12 players merely addresses a formal requirement. The substantive rules for the international transfer of minors (irrespective whether below or above 12 years of age) are found in Article 19 RSTP, including paragraph 2 of that article.[61] This led the Panel to conclude that “no ITC was required when the transfers occurred for players below the age of 12; their transfer nevertheless, can only be lawful if it complies with the requirements embedded in Article 19(2) RSTP”.[62] The Panel also noted the amendment to Article 9(4) RSTP, effective as of 1 March 2015, which lowered the age at which an ITC is required from 12 to 10.[63]

In short, the CAS also ruled that FC Barcelona had violated Article 19(3) RSTP in relation to one minor, for the same reasons referred to in its findings under Article 19(1) RSTP.[64] Moreover, six cases violated Article 19(4) RSTP, as the Catalonian association had failed to refer these transfers to the PSC sub-committee. These infringements of paragraph 4 further justify that “sanctions may also be imposed (…) on the clubs that reached an agreement for the transfer of a minor”. The CAS in this regard defined the interpretation of the word “agreement” to include “agreements concluded between the registering club and the player himself, his parents, agents, etc”.[65] Further, the Panel established a breach of Article 19bis RSTP for all 31 players under investigation.[66] This constitutes a procedural violation, being “the lack of reporting of information regarding the progress and development of players” attending FC Barcelona’s well-known academy ‘La Masía’”.[67] Be that as it may, the CAS did praise the training and educational track record of La Masía. Thereby it deviated from the Appeal Committee’s ruling. In opposition to the latter it found that the attending players’ potential football careers are not endangered. On the contrary, if FC Barcelona in the future commits itself to its reporting duties under Article 19bis RSTP, then it “will be contributing to the overarching principles governing the protection of minors, since it will be providing other clubs with an enviable benchmark for the education and training of players”.[68] The CAS Panel found the sanctions imposed by the FIFA Disciplinary Committee and the Appeal Committee to be proportionate, and hence confirmed the earlier verdict.[69] Concretely, FC Barcelona was imposed a transfer ban for two transfer periods, as well as a fine of CHF 450,000.[70]


The RFEF case and latest developments

Things had not completely settled down yet with regard to the Spanish national football association: Real Federación Española de Fútbol (“RFEF”).[71] As has become clear in the coverage of the Barcelona case, apparent mistakes were made in the Spanish supervision of the ban on international transfers of minors. In a dispute regarding 31 international minor transfers to several Spanish football clubs[72], the RFEF was found by the CAS to have violated its guarding role and thereby induced a passive infringement of Articles 19(1), 19(3), 19(4) together with Annexes 2 and 3, and Articles 5(1) and 9(1) RSTP. [73] A fine of CHF 280,000 was imposed. The Panel pointed out that the RFEF could not justify its failure by arguing that the RSTP was conflicting with Spanish law, given that the rules on the protection of minors had come about in the 2001 agreement between FIFA/UEFA and the EU, which was acknowledged by Spain as a Member State of the EU.[74] Also, for 21 players below the age of 12 the RFEF had failed to fulfil its notification obligations, which the Panel condemned for the exact same reasons as in the FC Barcelona case.[75] The RFEF had failed to “make use of the statutory frameworks and tools at its disposal to ensure the full protection of minors”, and was found negligent as it failed to ensure that clubs and regional associations strictly complied with Article 19.[76] Furthermore, it had in some cases not fulfilled its obligation to seek the approval of the PSC subcommittee nor even submitted an application for such transfers.[77]

Ultimately in 2016, a fate similar to that of “Barça” fell upon both Atlético and Real Madrid.[78] The concise FIFA press release indicates that investigations were conducted by FIFA TMS, which “concerned minor players who were involved and participated in competitions with the clubs over various periods”, between roughly 2005 and 2014. Both clubs were sanctioned for violating, amongst others, Articles 19 and 19bis as well as annexe 2 of the RSTP. The clubs appealed (by which the sanctions were temporarily lifted), yet in September 2016 these appeals were similarly rejected by FIFA’s Appeal Committee.[79] This meant that Atlético Madrid and Real Madrid will have to serve a transfer ban lasting two consecutive transfer periods (e.g. until January 2018), during which they will not be able to attract any players, and were fined CHF 900,000 and CHF 360,000 respectively. The clubs were given a 90 day period “to regularise the situation of all minor players concerned”.[80] A little over a week later, Real Madrid informed the CAS that it would appeal FIFA’s decision before the court in Lausanne.[81] The final outcome of this appeal is still unknown.

In a similar vein, very recently, the English club Manchester City has come under suspicion for allegedly wanting to transfer a 15-year-old player from Argentina, while the Dutch club Ajax was denied by the CAS to sign an American player aged 15.[82] These cases exemplify that clubs might just not be ready to put the practice of internationally transferring minors to bed yet. Moreover, the adaptation of the relevant rules is a sign for the need of continuous monitoring the effect of the provision on the protection of minors. The latest update, the June 2016 version, has incorporated another exception to the prohibition for the international transfer of minors, which has been created through the Sub-Committee’s case law.[83] Players that have for the five years preceding the request continuously lived in the country (other than that of their nationality) of intended registration are now exempted from the prohibition.[84]

In this part 2 of the blog, I have shown that FIFA’s restrictions on minor transfers have become more stringent after the 2009 reform. In recent years, FIFA has also cracked down on various prominent clubs, especially in Spain, which were still involved in recruiting minor players while disregarding, with the tacit support of their national federation, FIFA’s rules. Unsurprisingly, these developments have also flared up again the debate on the compatibility of those rules with EU law.[85] Thus, the next, third and final, part of this blog on FIFA’s provision on the protection of minors will offer a substantive assessment of FIFA’s rule under the requirements of EU Internal Market law. 




[1] A. Najarian, “’The Lost Boys’: FIFA's Insufficient Efforts To Stop Trafficking of Youth Footballers”, Sports Law. J. 2015, p. 167; R. Simons, “Protection of Minors vs. European Law”, Eur Sports Law Bulletin 2010, p. 172.

[2] R. Simons, “FIFA Transfer Matching System wel effectief?”, TvS&R 2011, p. 100.

[3] FIFA Circular no. 1190, 20 May 2009.

[4] Ibid.

[5] Art. 19(4) FIFA RTSP 2009.

[6] FIFA Circular no. 1206, 13 October 2009.

[7] FIFA Circular 1209, 30 October 2009.

[8] Art. 19bis FIFA RSTP 2009.

[9] Definition 12 FIFA RSTP 2009.

[10] Art. 19bis(1) and (2) FIFA RSTP 2009; Supra at 5.

[11] V. Derungs, “Protecting underage football players in the transfer system”, World Sports L. Report 2015, p. 15.

[12] Definition 13 FIFA RSTP 2016.

[13] N. St. Cyr Clarke, “The beauty and the beast: Taming the ugly side of the people’s game”, 2011 Columbia Journal of European Law, p. 619.

[14] FIFA Circular No. 1174, 12 January 2009.

[15] Annexe 2 FIFA RSTP 2016

[16] Art. 3(2) Annexe 2 FIFA RSTP 2009.

[17] Art. 5(1) Annexe 2 FIFA RSTP 2009.

[18] Art. 5(2) Annexe 2 FIFA RSTP 2009.

[19] FIFA Document, Protection of minors – Pertinent facts to be included in documents.

[20] Art. 9 and Annexe 3 FIFA RSTP 2009.

[21] For precise steps see FIFA TMS, Global Transfer Market Report 2016, p. 8; Supra at 4, p. 101.

[22] FIFA, Transfers, Player’s status, Clubs, Agents Regulations - Archived regulations

[23] Arbitration CAS 2011/A/2354 E. v. Fédération Internationale de Football Association (FIFA), award of 24 August 2011: At the same time, he participated in a three-year educational/trainee program at a company in Frankfurt, which aimed “to prepare him as office clerk to apply for a job as ‘Airport Manager’”. The German national football association, on behalf of Muhic and Kickers Offenbach made a request to FIFA for an exception via a special authorization for the transfer, founded on the “hardship based on the specific circumstances of the present case, namely the move of the player from Bosnia and Herzegovina to Germany without his parents, but with their expressed consent, for reasons not linked to football but to benefit from a humanitarian educational project” (p. 2.).

[24] Ibid, para. 17.

[25] Ibid, para. 18.

[26] Ibid, para. 18 and p. 2; Furthermore, the Panel recalled that Bosnia and Herzegovina is neither a member of the EU nor of the EEA and, as a consequence thereof, a player with this nationality cannot rely on the exception of Article 19(2)(b) RSTP (para. 20). The Panel subsequently, by emphasizing that the rationale for this exception is the “free movement of services and services suppliers within the EU and the EEA (and other production factors)”, quickly dismissed the appellant’s claim for the application of this provision resting on “the Stabilization and Association Agreement signed between the EU and Bosnia and Herzegovina” (paras. 21-23). In final, the CAS once more indicated that Article 19’s rationale was not to stop voluntary movement, yet it felt compelled to apply the protection of minors strictly: “Opening up the door to exceptions beyond those carefully drafted and included in the present text would unavoidably lead to cases of circumvention of the rationale for this provision” (para. 26). Moreover, Muhic could still continue his education, which was his primary reason to move to Germany, and likewise train with his team. He did have to wait a few months before becoming 18 years of age and thus eligible to start in professional matches. Nevertheless, the Panel concluded that this could not amount to constitute an “exceptional hardship going beyond the general impact of the provisions on the protection of minors” (para. 27).

[27] Supra at 11, p. 15.

[28] Arbitrage TAS 2012/A/2862 FC Girondins de Bordeaux c. Fédération Internationale de Football Association (FIFA), sentence du 11 janvier 2013 (Vada II); Arbitrage TAS 2011/A/2494 FC Girondins de Bordeaux c. Fédération Internationale de Football Association (FIFA), sentence du 22 décembre 2011 (Vada I).

[29] TAS 2012/A/2862 (Vada II), para. 3.

[30] Ibid, para. 18.

[31] Ibid, para. 19.

[32] Ibid, para. 19; Bulletin TAS CAS Bulletin 2014/2, p. 29.

[33] Supra at 29, para. 91.

[34] Ibid, para. 94.

[35] Ibid, para. 95.

[36] CAS 2008/A/1485 FC Midtjylland A/S v. Féderation Internationale de Football Association, paras. 19-21.

[37] Supra at 29, para. 96; Bulletin TAS CAS Bulletin 2014/2, p. 29.

[38] Supra at 29, para. 97.

[39] Ibid, paras. 98-100.                                                                                                                                                                  

[40] The Guardian, 29 April 2015, “Atlético Madrid and Real deny reports they are facing Fifa transfer embargo”.

[41] Arbitration CAS 2013/A/3140 A. v. Club Atlético de Madrid SAD & Real Federación Española de Fútbol (RFEF) & Fédération Internationale de Football Association (FIFA), award of 10 October 2013.

[42] CAS 2005/A/955 Càdiz C.F., SAD v FIFA and Asociación Paraguaya de Fútbol and CAS 2005/A/956 Carlos Javier Acuña Caballero v/FIFA and Asociación Paraguaya de Fútbol; CAS 2008/A/1485 FC Midtjylland A/S v. Féderation Internationale de Football Association.

[43] Supra at 41, paras. 8.20-8.23.

[44] TAS 2011/A/2494 FC (Vada I), paras. 31-38.

[45] Supra at 41, paras. 8.25.

[46] Ibid, para. 8.30.

[47] Ibid, para. 8.31.

[48] Ibid, paras. 8.32-36.

[49] Arbitration CAS 2014/A/3611 Real Madrid FC v. Fédération Internationale de Football Association (FIFA), award of 27 February 2015: The PSC Sub-Committee had rejected the request, which was again founded on the “parent rule”. It did so inter alia since the player’s parents had merely obtained a temporary residence permit that denied them the right to work, while the submitted employment contracts “made reference to enterprises incorporated and domiciled in Venezuela” (para. 11). This in combination with the fact that the player had moved to Spain one month in advance of his parents, led the PSC to believe that their move was linked to Real Madrid’s interest in their son (paras. 12-14). The subsequent proceedings before the CAS are only of interest in relation to the procedural aspects, since the appeal was declared inadmissible and consequently did not address the merits (paras. 63-66).

[50] CAS 2014/A/3793 Fútbol Club Barcelona v. Fédération Internationale de Football Association (FIFA), award of 24 April 2015.

[51] Bulletin TAS CAS Bulletin 2015/2, p. 76; Supra at 52, paras. 2.3-2.11.

[52] Supra at 50, para. 2.2.

[53] Supra at 51, p. 77.

[54] Supra at 50, paras. 9.1-9.2.

[55] Ibid, paras. 9.2-9.3.

[56] Ibid, para. 9.4.

[57] Ibid.

[58] Ibid.

[59] Ibid, para. 9.7.

[60] Ibid.

[61] Ibid, para. 9.8.

[62] Ibid.

[63] Ibid, para. 9.9.

[64] Ibid, paras. 9.10-9.12.

[65] Ibid, para. 9.14.

[66] Ibid, para. 9.18.

[67] Ibid, para. 9.19.

[68] Ibid.

[69] Ibid, paras. 9.29-9.36 and 10.

[70] Ibid, para. 2.18.

[71] CAS 2014/A/3813 Real Federación Española de Fútbol (RFEF) v. Fédération Internationale de Football Association (FIFA), 27 November 2015.

[72] Coincidentally the exact same number of minors under investigation as in the FC Barcelona Case. Be that as it may, in the case a hand the minors transferred to various Spanish clubs.

[73] Bulletin TAS CAS Bulletin 2016/1. P. 66.

[74] Ibid, p. 63, the Panel stated “As a member of the European Union, the Kingdom of Spain had acknowledged the application of this general prohibition throughout Spain and no express Spanish law stating otherwise had been brought to the Panel’s attention”.

[75] Supra at 73, p. 63.

[76] Ibid, p. 64.

[77] Ibid.

[78] FIFA, 14 January 2016, “Atlético de Madrid and Real Madrid sanctioned for international transfers of minors”.

[79] FIFA, 8 September 2016, “FIFA rejects appeals of Atlético de Madrid and Real Madrid in relation to transfers of minors”.

[80] The Guardian, 8 September 2016, “Real Madrid and Atlético Madrid lose appeals against Fifa transfer ban”.

[81] CAS, 16 September, “Request for stay filed by Real Madrid CF granted by the Court of Arbitration for Sport”.

[82] Independent, 22 September 2016, “Manchester City could face transfer ban after being reported to Fifa for 'trafficking' of youngster”; USA Today, 29 October 2016, “CAS rejects US teenager’s challenge to FIFA transfer rules”.

[83] Supra at 11, p. 15; FIFA Circular no. 1542, 1 June 2016.

[84] Art. 19(3) FIFA RSTP 2016.

[85] Reuters, 24 November 2016, “FIFA faces lawsuit over rules banning transfer of minors”.

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Asser International Sports Law Blog | Resolution of Disputes Arising From Football Contracts in Turkey. By N. Emre Bilginoglu

Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

Resolution of Disputes Arising From Football Contracts in Turkey. By N. Emre Bilginoglu

Editor’s note: N. Emre Bilginoglu[1] is a lawyer based in Istanbul. His book entitled “Arbitration on Football Contracts” was published in 2015.


Introduction

With a total market value of approximately 911 million EUR, the Turkish Super League ranks as one of the prominent football leagues in Europe. Five of the eighteen teams that make up half of the total market value are based in Istanbul, a busy megalopolis that hosts a population of fifteen million inhabitants.[2] As might be expected, the elevated market value brings forth a myriad of disputes, mainly between the clubs and the players. However, other crucial actors such as coaches and agents are also involved in some of the disputes. These actors of the football industry are of all countries, coming from various countries with different legal systems.

One corollary of rapid globalisation is the development of transnational law, which is quite visible in the lex sportiva.[3] Like foreign investors, foreign actors of the sports industry look for some legal security before signing a contract. FIFA does protect these foreign actors in some way, providing players and coaches legal remedies for employment-related disputes of an international dimension. But what if the legal system of the FIFA member association does not provide a reasonable legal remedy for its national actors?[4]

That is why lawyers who are involved in sports related disputes have to guide their law-makers in improving their legal systems after thoroughly examining the dispute resolution mechanisms of other countries. Arbitration is indeed growing exponentially as a method of dispute resolution.[5] The renowned alternative dispute resolution is especially preferred in disputes arising from sports contracts, where both a rapid and a confidential resolution is of the essence.[6]  However, some legal systems oblige the parties of a sports related dispute to resolution by arbitration whereas some legal systems do not. This article gives the reader an insight about resolution of disputes arising from football contracts in Turkey. 


Turkish Method of Dispute Resolution

In August 2015, the Turkish Football Federation made certain changes in its Statute and guidelines. Since those changes, disputes arising from contracts between football clubs, players, coaches and agents are resolved within the Turkish Football Federation Dispute Resolution Board (“UCK”).[7] Therefore, applying to State courts for these disputes (the previous way of resolving disputes) is now impossible, which is a substantial legal issue.

Article 59 of the Turkish Constitution states that disputes related to sports administration and disciplinary matters should be resolved by mandatory arbitration.[8] Decisions of these kinds cannot be appealed to any court of the judiciary. The scope of this article does not include employment related disputes. Article 9 of the Constitution declares that judicial power shall be exercised by independent courts. However, courts do not have jurisdiction to hear disputes arising from football contracts because of the regulations of the Turkish Football Federation. Kelsen’s hierarchy of laws is indeed upside down, alas, the current practice without a proper legal basis is the actual practice. It does not seem like a change is scheduled in the near future, given that many are grateful for the rapid resolution of disputes.

The UCK consists of a “Board of Presidents” and arbitrators. It carries out a simple arbitration process and it involves two arbitrators and a UCK official. The applicant is responsible for the application fee (3% of the disputed amount) and paying the arbitrators' fees, which are decided by UCK (between about 450 and 1500 Euros per arbitrator). The UCK decides within four months (they have the right to extend the time limit for a month based on justified grounds). The decision of the UCK may be appealed to the Turkish Football Federation Appeals Board. However, this appeal does not obstruct the enforcement of the award. Although the statute of the Turkish Football Federation recognizes the competence of CAS, it also declares that the decisions rendered by the Appeals Board cannot be reviewed by CAS.[9]

Decisions of the UCK are not published. Decisions of the Arbitral Tribunal are published without reasoning. Hence, it is impossible to know both the facts of the case and how the arbitral tribunal reached a verdict. This negatively impacts the predictability of the UCK and the Arbitral Tribunal.

The proper composition of the UCK is an important condition for fair and equitable proceedings.[10] Arbitrators are nominated by the Foundation of the Clubs, the Association of Football Players and the Association of Coaches. These three institutions may nominate up to 25 arbitrators each. However, the Turkish Football Federation board of directors appoints the arbitrators from the list of nominees, thus casting a shadow on the independence and the impartiality of the arbitral tribunal, which are crucially important for the right to a fair trial.[11] There are numerous links between the UCK, the Arbitral Tribunal and the Turkish Football Federation. The Federation finances the UCK and the Arbitral Tribunal, can modify the Statutes of the UCK and the Arbitral Tribunal and it appoints the arbitrators of the UCK and the members of the Arbitral Tribunal. The current formation of the UCK resembles CAS before Gundel reforms.

Sporting sanctions and training compensations are also within the scope of the UCK.[12] Decisions of the UCK may only be appealed to Arbitral Tribunal of the Turkish Football Federation. The lack of a judicial review for these decisions is disconcerting. I believe the involvement of the Swiss Federal Tribunal in the CAS process could serve as a good model. CAS decisions may be appealed to the Swiss Federal Tribunal but there is no court in Turkey to appeal to once the Arbitral Tribunal decides on the matter. A general court or the Turkish Court of Cassation must review the decisions of the Arbitral Tribunal regarding disputes on football contracts. Decisions of the Arbitral Tribunal related to sports administration and disciplinary matters are accurately not appealable, as stated by Article 59 of the Constitution. However, Article 59 of the Constitution does not include personal actions. Article 9 of the constitution declares that the judicial power shall be exercised by independent courts. The right to access to courts that is granted by the Constitution cannot be breached by an amendment of the Turkish Football Federation. Therefore, courts are wrong for denying jurisdiction for disputes arising from football contracts. 


Players

The rights and obligations between clubs and players are determined by an employment agreement.[13] In Turkey, labour courts have jurisdiction on disputes arising from employment agreements. However, the Turkish Labour Code does not apply to players, thus surprisingly excluding the jurisdiction of labour courts for disputes regarding them. Article 4 of the Labour Code states that the Code does not apply to athletes. The reason behind this exclusion is not to grant certain rights and benefits to athletes, such as severance payments. Before the amendments of August 2015 came into force, disputes regarding players were resolved in general courts, not labour courts. The debate whether general courts or labour courts have jurisdiction is now obsolete, as the players have to apply to the UCK for the disputes arising from football contracts.

The FIFA DRC adjudicates on cases regarding employment related disputes between a club and a player of an international dimension, therefore foreign players do not have to apply to the UCK. In a case of dual citizenship (the player was British/ Turkish), CAS awarded that someone who benefits from Turkish citizenship should also accept its possible burdens, thus refusing jurisdiction.[14]

Arbitration is indubitably more preferable compared to courts for players. The UCK decides within four months and the decision is enforced by the Turkish Football Federation right away. This promptitude surely provides an advantage for players. Nevertheless, arbitrators’ fees are a hefty burden for destitute amateur players or pro players of the third league. On the contrary, application fees that are three percent of the disputed amount is a supernumerary amount for high earning players. High arbitration cost is a concern, as it is strictly related to right of access to courts. Costs should not victimize the plaintiff. 


Coaches

The FIFA PSC adjudicates on disputes between a club and a coach of an international dimension. Turkish coaches working in Turkey do not have that option. Before the implementation of the mandatory arbitration, labour courts had jurisdiction over the disputes arising from employment agreements of coaches. As of August 2015, coaches may only apply to the UCK for disputes arising from their contracts.

The Turkish Super League clubs do not prefer stability with regard to their coaches, as only one team in the league started the 2016-2017 season with the same coach for the third consecutive year. Coaches seem content with the rapid resolution of their contractual disputes and the confidentiality provided by arbitration, however, arbitrators within UCK are seldom appointed by them.


Agents

The FIFA Regulations on the Status and Transfer of Players state that the PSC has no jurisdiction to hear any contractual dispute involving intermediaries. Agents, foreign or not, have to apply to the UCK for disputes arising from their contracts. This is overall problematic for agents, because they do not have any say on the appointment of arbitrators. Therefore, the independence and the impartiality of the UCK is suspicious, especially for agents. It is highly recommended for foreign agents to work with Turkish lawyers doing business in Turkey. If not, they will have to hire one at some point.  


Conclusion

Arbitration does truly offer a structure that is football-oriented and more aware of the realities of modern football, as stated in the preamble of FIFA NDRC Standard Regulations. “National” arbitration of football related disputes is evolving. The fact that this is genuinely a developing method of dispute resolution should encourage practitioners to improve their national legal systems. Practitioners and those who are in the football business may quite easily benefit from such improvement because it would only influence the business positively. In the Turkish context I would advise the following:

First, decisions not regarding disputes related to sports administration and disciplinary matters of the Arbitral Tribunal should be appealable. This would provide the right to access to courts, as granted by the Constitution.

Second, the independence and the impartiality of the UCK is still a problematic issue that needs to be tackled. The UCK should not be within the structure of the Turkish Football Federation. The process of the appointment of arbitrators should be revised. Clubs, players, coaches and agents must have an equal say on the matter.

The current Turkish system is preferable compared to everlasting court process. Four months to receive an award and the assurance of the enforcement of the award by the Turkish Football Federation is quite encouraging. Mandatory arbitration of UCK is very recent and hopefully the novel system will evolve to fulfil the criteria of FIFA.



[1] Nurettin Emre Bilginoglu, LLM, Attorney-at-law

 Istanbul, Turkey

 e-mail: emre@caglayanyalcin.com

[2] http://www.transfermarkt.com/super-lig/startseite/wettbewerb/TR1

[3] Duval (2013) Lex Sportiva: a playground for transnational law. Eur Law J 19:822-842.

[4] Preamble of the FIFA National Dispute Resolution Chamber Standard Regulations points at this issue:

 “Currently, only a limited number of member associations have a national dispute resolution chamber or a body structured along similar lines that fulfils the criteria of article 22 paragraph b) of the Regulations on the Status and Transfer of Players. This means that the vast majority of international employment-related disputes fall within the jurisdiction of the FIFA Dispute Resolution Chamber and that the majority of “national” cases may not find appropriate solutions.”

[5] See Ashford (2014) Handbook on International Commercial Arbitration. JurisNet LLC, New York and Karton (2013) The Culture of International Arbitration and the Evolution of Contract Law. Oxford University Press, Oxford.

[6] See Rigozzi (2005) L’arbitrage international en matière de sport. Helbing & Lichtenhahn, Basel.

[7] See Eksi N (2015) Spor Tahkim Hukuku. Beta, Istanbul and Bilginoglu N (2015) Resolution of Disputes Arising From Football Contracts. Beta, Istanbul.

[8] Artıcle 59- The State shall take measures to develop the physical and mental health of Turkish citizens of all ages, and encourage the spread of sports among the masses. The State shall protect successful athletes. (Paragraph added on March 17, 2011; Act No. 6214) The decisions of sport federations relating to administration and discipline of sportive activities may be challenged only through compulsory arbitration. The decisions of Board of Arbitration are final and shall not be appealed to any judicial authority.

[9] “…the TFF Statutes and the Turkish Football Law expressly exclude any appeal against national arbitral tribunals’ decisions, i.e. against such a decision like the Appealed Decision which is the object of the present case. The particular trumps the general. Therefore the argument of the Player that he has an express right of appeal to the CAS under the TFF Statutes must be rejected.” See CAS 2010/A/1996 Omer Riza v. Trabzonspor Kulübü Dernegi & Turkish Football Federation (TFF).

[10] CAS 2015/A/4172 Association of Unions of Football Players and Coaches v. Football Union of Russia.

[11] Although the formation of the arbitral tribunal was different, see CAS 2006/O/1055 Del Bosque, Grande, Miñano Espín & Jiménez v/ Besiktas. For European Court of Human Rights decisions, see Terra Woningen B.V. v. Netherlands, Application N:     20641/92, Date: 17/12/1996; Tsfayo v. UK, Application N: 60860/00, Date: 14/11/2006.

[12] See de Weger (2016) The Jurisprudence of the FIFA Dispute Resolution Chamber, T.M.C. Asser Press for extensive information on sporting sanctions and training compensations.

[13] De Weger (2016) p. 132; For the German practise, see Frodl C (2016) Neuer, Hummels, Muller, Gotze & Co: the legal framework governing industrial relations in German professional football, Int Sports Law J (2016) 16:3–21.

[14] CAS 2010/A/1996 Omer Riza v. Trabzonspor Kulübü Dernegi & Turkish Football Federation (TFF). 

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Asser International Sports Law Blog | The International Sports Law Digest – Issue I – January-June 2014 (by Frédérique Faut)

Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

The International Sports Law Digest – Issue I – January-June 2014 (by Frédérique Faut)

The International Sports Law Digest will be a bi-annual post gathering recent material on International and European Sports Law. This is an attempt at providing a useful overview of the new, relevant, academic contributions, cases, awards and disciplinary decisions in the field of European and International Sports Law. If you feel we have overlooked something please do let us know (we will update the post).

Antoine Duval


Literature


SSRN Corner:

1. Jack Anderson, ‘Match Fixing and Money Laundering’, April 14, 2014

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2424755

2. Antoine Duval, ‘Cocaine, Doping and the Court of Arbitration for Sport -- 'I Don't Like the Drugs, But the Drugs Like Me'’, April 29, 2014

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2430901

3. Antonio Rigozzi, Marjolaine Viret, Emily Wisnosky, ‘Latest Changes to the 2015 WADA Code – Fairer, Smarter, Clearer… and not Quite Finished’, January 20, 2014

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2412012

4. Jack Anderson, ‘Sporting Justice: An Arbitrator's Perspective’, April 15, 2014

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2425154

5. Antonio Rigozzi, Brianna Quinn, ‘Evidentiary Issues Before CAS’, May 19, 2014

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2438570

6. Antonio Rigozzi & Erika Hassler, ‘Sports Arbitration Under the CAS Rules’, June 7, 2014 http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2446612

 

The International Sports Law Journal: 

1. Alfonso Valero, ‘In search of a working notion of lex sportiva, The International Sports Law Journal, Volume 14, Issue 1-2, June 2014, p. 3-11

http://link.springer.com/article/10.1007/s40318-014-0041-9

2. Rosmarijn van Kleef, ‘The legal status of disciplinary regulations in sport’, The International Sports Law Journal, Volume 14, Issue 1-2, June 2014, p. 24-45

http://link.springer.com/article/10.1007/s40318-013-0035-z

3. Johan-Michel Menke, ‘What to know about international football player transfers to Germany’, The International Sports Law Journal, Volume 14, Issue 1-2, June 2014, p. 46-57

http://link.springer.com/article/10.1007/s40318-013-0037-x

4. Alexandra Veuthey, ‘Match-fixing and governance in cricket and football: what is the fix?’, The International Sports Law Journal, Volume 14, Issue 1-2, June 2014, p. 82-114

http://link.springer.com/article/10.1007/s40318-014-0038-4

5. Salomeja Zaksaite, Hubert Radke, ‘The interaction of criminal and disciplinary law in doping-related cases’, The International Sports Law Journal, Volume 14, Issue 1-2, June 2014, p. 115-127

http://link.springer.com/article/10.1007/s40318-014-0045-5

6. Helmut Dietl, Christian Weingärtner, ‘Betting scandals and attenuated property rights: how betting-related match-fixing can be prevented in future’, The International Sports Law Journal, Volume 14, Issue 1-2, June 2014, p. 128-137

http://link.springer.com/article/10.1007/s40318-014-0040-x

7. Karen Jones, ‘Lunch and learn: WADA Code 2015 – the key changes’, The International Sports Law Journal, Volume 14, Issue 1-2, June 2014, p. 143-147

http://link.springer.com/article/10.1007/s40318-014-0046-4

 

Jeffrey S. Moorad Sports Law Journal

8. Haight, Randy, ‘Alleging an Anticompetitive Impact on a Discernible Market: Changing the Antitrust Landscape for Collegiate Athletics’, 21 Jeffrey S. Moorad Sports Law Journal (2014), p. 19-38

http://www.heinonline.org.proxy.library.uu.nl/HOL/Index?index=journals%2Fvse&collection=journals

 

Vanderbilt Journal of Transnational Law:

1. Cox, Thomas Wyatt, ‘The International War against Doping: Limiting the Collateral Damage from Strict Liability’, Vanderbilt Journal of Transnational Law, Vol. 47, Issue 1 (January 2014), pp. 295-330

http://www.heinonline.org.proxy.library.uu.nl/HOL/Page?handle=hein.journals/vantl47&div=8&collection=journals&set_as_cursor=66&men_tab=srchresults&terms=WADA&type=matchall

 

Indonesian Journal of International & Comparative Law:

1.  Shingal, Ankur, ‘The Olympic Curse; Protecting the Olympic Dream for Host Cities and Their Inhabitants’, Indonesian Journal of International & Comparative Law, Vol. 1, Issue 2 (April 2014), p. 572-607

http://www.heinonline.org.proxy.library.uu.nl/HOL/Page?handle=hein.journals/indjicl1&div=24&collection=journals&set_as_cursor=11&men_tab=srchresults&terms=(Court%20of%20Arbitration%20for%20Sport)&type=matchall

 

Berkeley Journal of Entertainment and Sports law:

1. Adriano Pacifici, ‘Scope and Authority of Sports League Commissioner Disciplinary Power: Bounty and Beyond’, 3 Berkeley J. Ent. & Sports L. (2014)

http://scholarship.law.berkeley.edu/bjesl/

2. John A. Fortunato, ‘Sponsorship Implications of the Lance Armstrong v. USPS Lawsuit’, 3 Berkeley J. Ent. & Sports L. (2014)

http://scholarship.law.berkeley.edu/bjesl/

 

Not published yet:

1. Matthew J. Mitten. 2014. ‘The Court of Arbitration for Sport and its Global Jurisprudence: International Legal Pluralism in a World Without National Boundaries’ ExpressO

http://works.bepress.com/matt_mitten/2/

  

Cases


TAS / CAS Awards (Published on CAS website)

 CAS 2013/A/3258 Besiktas Jimnastik Kulübü v. UEFA

http://www.tas-cas.org/d2wfiles/document/7527/5048/0/Award20final20325820(internet).pdf

CAS 2013/A/3274 Mr Mads Glasner v. Fédération Internationale de Natation (FINA)

http://www.tas-cas.org/d2wfiles/document/7320/5048/0/Award203274(FINAL)20internet.pdf

CAS arbitration N° OG 14/01 Daniela Bauer v. AOC & ASF

http://www.tas-cas.org/d2wfiles/document/7310/5048/0/Award2014-0120(FINAL).pdf

CAS arbitration N° OG 14/02 Clyde Getty v. FIS

http://www.tas-cas.org/d2wfiles/document/7330/5048/0/CAS20Award2014-0220(FINAL)20internet.pdf

CAS arbitration N° OG 14/03 Maria Belen Simari Birkner v. COA & FASA

http://www.tas-cas.org/d2wfiles/document/7354/5048/0/DOC.pdf

CAS arbitration N° OG 14/04-05 ACA, COC & SOC v. FIS & IOC

http://www.tas-cas.org/d2wfiles/document/7378/5048/0/Award.pdf

CAS 2012/A/2857 Nationale Anti-Doping Agentur Deutschland v. Patrick Sinkewitz

http://www.tas-cas.org/d2wfiles/document/7429/5048/0/Award20285720(FINAL).pdf

CAS 2014/A/3487 Veronica Campbell-Brown v. The Jamaica Athletics Administrative

Association (JAAA) & The International Association of Athletics Federations (IAAF)

http://www.tas-cas.org/d2wfiles/document/7467/5048/0/Award20348720_internet_.pdf

CAS 2013/A/3395 Anderson Luís De Souza v. CBF & FIFA

http://www.tas-cas.org/d2wfiles/document/7523/5048/0/Consent20Award20Final20339520 (201420052026).pdf

TAS 2012/A/2720 FC Italia Nyon c/ LA de l’ASF & ASF & FC Crans

http://www.tas-cas.org/d2wfiles/document/7531/5048/0/sentence20272020(FINAL)20caviardée. pdf

 

FIFA Dispute Resolution System


Club v. Club Disputes

Decision of the Single Judge of the Players’ Status Committee, Club A from country F v. Club B from country T

http://www.fifa.com/mm/document/affederation/administration/02/35/37/01/0114209%5fenglish.pdf

Decisión del Juez Únicode la Comisión del Estatuto del Jugador, Club C de país P c. Club D de país K

http://www.fifa.com/mm/document/affederation/administration/02/35/37/22/0114584%5fenglish.pdf

Decision of the Single Judge of the Players’ Status Committee, Club Z from country B v. Club P from country G

http://www.fifa.com/mm/document/affederation/administration/02/35/37/08/01141680%5fenglish.pdf

Decision of the Single Judge of the Players’ Status Committee, Club D from country C v. Club F from country S

http://www.fifa.com/mm/document/affederation/administration/02/35/37/15/01142777%5fenglish.pdf

 

Players’ And Match Agents Disputes

Décision du juge unique de la Commission du Statut du Joueur, l’agent A de pays T c. Joueur M de pays C

http://www.fifa.com/mm/document/affederation/administration/02/35/36/94/1141614%5fenglish.pdf

 

FIFA Dispute Resolution Chamber Decisions

Decision of the Dispute Resolution Chamber, A from country S v. O from country C

http://www.fifa.com/mm/document/affederation/administration/02/35/36/73/114396%5fenglish.pdf

Decision of the Dispute Resolution Chamber (DRC) judge, Club S from country J v. Player L from country R

http://www.fifa.com/mm/document/affederation/administration/02/34/23/10/01141223%5fenglish.pdf

Decisión de la Cámara de Resolución de Disputas, H del país A c. Club J del país B

http://www.fifa.com/mm/document/affederation/administration/02/35/36/66/1141678%5fenglish.pdf

Decision of the Dispute Resolution Chamber (DRC) judge, Player N from country F v. Club K from country L

http://www.fifa.com/mm/document/affederation/administration/02/35/36/45/01143001%5fenglish.pdf

Decision of the Dispute Resolution Chamber (DRC) judge, Player V from country B v. Club E from country I

http://www.fifa.com/mm/document/affederation/administration/02/35/36/52/01143003%5fenglish.pdf

Decision of the Dispute Resolution Chamber (DRC) judge, Player N from country F v. Club A from country L

http://www.fifa.com/mm/document/affederation/administration/02/34/23/03/01143342%5fenglish.pdf

Decisión del juez de la Cámara de Resolución de Disputas (CRD), Juagdor M de país A c. Club O de país P

http://www.fifa.com/mm/document/affederation/administration/02/35/36/59/01143418%5fenglish.pdf

Decision of the Dispute Resolution Chamber, Player F from country T v. Club K from country R

http://www.fifa.com/mm/document/affederation/administration/02/35/36/87/0214728%5fenglish.pdf

Decision of the Dispute Resolution Chamber, Player E from country F v. Club S from country B

http://www.fifa.com/mm/document/affederation/administration/02/35/36/80/02143251%5fenglish.pdf

 

National court decisions

Landgericht München, February 26 2014, file no. 37 O 28331/12 (Claudia Pechstein v. ISU)

http://www.justiz.bayern.de/gericht/lg/m1/presse/archiv/2014/04261/index.php

Full text of the ruling available here.

Court of Labour Antwerp, May 6 2014, file no. 2009/AH/199 (Dahmane v. K. RACING CLUB GENK 322 VZW)

http://www.cass.be/arbeidshof/antwerpen/Publicaties/arrest2009AH199.pdf

 

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